Dutch Transfer Pricing Court Case on Business Restructuring:Preventing Transfer Pricing Disputes by Getting Certainty in Advance

This article summarizes a Dutch court case regarding a business re­structuring within a multinational enterprise,where the valuation of the transferred business activities was not confirmed by the tax authorities in advance.As a result of the lack of certainty beforehand,the taxpayer experienced a significant tax correc­tion.According to the author’s perspective,this situation could have been prevented by seeking certainty in advance.